Who exactly pays taxes under export agency model?

According to Article 18 of the 2025 "Administrative Measures for Value-Added Tax on Exported Goods and Services",when exporting goods through an agent,the taxpayer shall provide the following documents to the tax authority:"Whoever operates,whoever declares"After the export enterprise receives foreign exchange through the agency company,it needs to provide:

• Declarationentity:Agencycompanyholdingexportqualifications
• VATtaxpayer:Actualgoodsowner(consignor)
• Corporateincometaxdeclarationentity:
  • Agencyservicefeeincome–Agencycompany
  • ProfitfromGoodsSales–Consignor

Does the consignor need to issue VAT special invoices?

In 2025,the tax inspection will focus on the agent export invoice chain,which must include the following elements:

• Consignor→Agentissues13%VATspecialinvoice
• Agent→Foreignbuyerissuescommercialinvoice
• Thecustomsdeclarationformmustclearlyindicatethephrase"exportonbehalfof".

A case from 2024: A clothing company in Zhejiang was identified as "pretending to be a self-operated enterprise while actually acting as an agent" for failing to issue invoices to its agency,and was ordered to repay the tax refund and fined 1.2 million yuan.

How exactly are export tax refunds calculated and allocated?

Taking the 13% tax rebate rate for textiles in 2025 as an example:

• Agentsdeclaredrefundbase=Customsdeclarationamount×exchangerate
• Theactualtaxrefundamountshouldbefullyreturnedtotheprincipal
• Agencyservicefeesshouldbechargedseparately(recommendedcontractstipulation:1-3%ofcustomsdeclarationamount)

How does foreign exchange receipt and payment affect tax treatment?

According to the new policies announced by the State Administration of Foreign Exchange in 2025:

• Mustbeprocessedthroughtheagencycompanysforeignexchangeaccount
• Paymenttotheprincipalmustbecompletedwithin5workingdays
• Thebankreceiptmustbeannotatedwith"underagencyexport."

V.How to Avoid the Risk of "False Self-Operation,True Agency"?

The key violations that the General Administration of Customs will focus on inspecting in 2025:

• Agencyfeesbelow50%ofindustrystandards
• Fundcirculationcycleexceeding30days
• Customsdeclarationformnotindicatingagencyrelationship
• Itisrecommendedtoclarifyintheagencyagreement:
  • Goodsownershiptransferclauses
  • Qualityresponsibilitydivision
  • Irrevocablepaymentauthorization

VI.AgencyExportThere are何Special Regulations?

Regarding the new policies for cross-border e-commerce in 2025:

• Under9710/9810model,platformtransactiondatamustbeuploaded
• Retailexportsunder$150,000pershipmentcanusesimplifieddeclaration
• Overseaswarehousegoodsmustcompletetaxrefunddeclarationwithin6months

How to prepare supporting documents for tax audits?

It is recommended that enterprises establish a "three-stream integration" archive:

• Goodsflow:Customsdeclarationforms,shippingdocuments,warehousingrecords
• Fundflow:Foreignexchangereceipts/paymentvouchers,agencyfeeinvoices
• Documentflow:VATspecialinvoices,proformainvoices,foreignexchangeverificationforms

A compliance case: A mechanical manufacturer in Suzhou achieved zero problems in passing the tax inspection in 2024 by synchronizing the three-flow data in real time through the ERP system.